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                 NATIONAL HOUSING PARTNERSHIP REALTY FUND TWO
                         55 Beattie Place, P.O. Box 1089
                              Greenville, SC 29602

May 10, 2005

Correspondence Filing Via Edgar and Overnight Delivery

United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 0409
450 Fifth Street, NW
Washington, D.C.  20549
Attn:  Mr. Steven Jacobs

Re:   National Housing Partnership Realty Fund Two
      Form 10-KSB for the year ended December 31, 2004 File No. 0-14458

Ladies and Gentlemen:

This letter responds to the comments of the staff of the Securities and Exchange
Commission (the "Staff")  addressed to National Housing  Partnership Realty Fund
Two, a Maryland limited partnership (the "Partnership"), in a letter dated April
13, 2005.  The  Partnership  appreciates  the Staff's  willingness to provide an
extension of time for this response.  The Partnership's  response to the Staff's
comments are set forth below and are numbered to  correspond to the numbering of
the Staff's comments in the Staff's letter.

                        *     *     *     *     *

Form 10-KSB for the year ended December 31, 2004

Note 1 - Organization and Summary of Significant Accounting Policies

Significant Accounting Policies

1.         Comment:  In  a  supplemental  response,   please  tell  us  how  you
           determined  to account for your  investment  using the equity  method
           given  your  94.5%   interest  in  the  Local  Limited   Partnership.
           Specifically,  address the criteria for important rights in paragraph
           9 and the substance of the partnership arrangement in paragraph 10 of
           SOP 78-9.  Please cite relevant terms of the partnership  agreements,
           as appropriate.

            Response:  The Partnership made its initial determination to account
           for its investments in the local limited  partnership at the time the
           Partnership  became the limited partner investor in the local limited
           partnership. This evaluation included a review of the related limited
           partnership  agreement of the local limited partnership to understand
           the  rights  and   obligations   of  the  general   partner  and  the
           Partnership,  as limited partner. It should be noted that the general
           partner of the Partnership, The National Housing Partnership ("NHP"),
           also serves as the general partner of the local limited  partnership.
           The limited  partnership  agreement provides the general partner with
           the following rights and obligations:

o     The local limited  partnership  shall be managed and its business  shall
            be controlled by the general partner
o     Limited  partners  shall not take part in the  management  or control of
            the local limited partnership's business
o     The general  partner has the ability to designate the  management  agent
            for the local limited partnership
o     The general  partner is authorized to sell all or  substantially  all of
            the assets of the local limited partnership
o     The  limited  partner  does  not have the  right  to force  the  general
            partner to sell assets
o     The limited  partner does not have the right to structure the terms of a
            proposed sale of assets

           Although each general partner  historically  has controlled the major
           operational and financial  policies of the local limited  partnership
           for which it serves as general  partner by  exercising  the above and
           other rights stated in the respective limited partnership  agreement,
           the Partnership,  as limited partner,  has certain "important rights"
           as contemplated in paragraph SOP 78-9, as follows:

o    The limited partner has consent rights to the sale of all or  substantially
     all of the assets of the local limited  partnership  o The limited  partner
     has the right to  remove  the  general  partner  without  cause and elect a
     successor  general  partner upon a vote of the limited  partners  holding a
     majority (more than 50%) of the  percentage  interests in the local limited
     partnership.

           The Partnership  believes that these "important  rights" provide that
           the local limited  partnership is not under the control,  directly or
           indirectly,  of NHP and therefore  preclude NHP, as general  partner,
           from  consolidating  its investment in the local limited  partnership
           under  paragraph 9 of SOP 78-9. The  Partnership  further  considered
           whether  such  limited  partner  rights,   in  conjunction  with  the
           Partnership's  ownership  of  more  than a  majority  of the  limited
           partner interests, could effectively result in the Partnership having
           control  over the major  operational  and  financial  policies of the
           local  limited  partnership,  which would  result in the  Partnership
           consolidating  the  local  limited  partnership  in  accordance  with
           paragraph 10 of SOP 78-9.

           Notwithstanding the "important rights" of the limited partner and the
           Partnership's majority ownership,  the Partnership has concluded that
           it does not  control  the  local  limited  partnership,  based on two
           primary factors:  (1) the provisions of the local limited partnership
           agreement that specifically  provides operating and financial control
           to the  general  partner  and (2) the  demonstrated  exercise of that
           control by the general  partner over the  twenty-year  history of the
           local limited partnership.

           Based  on the  foregoing  considerations,  the  Partnership  does not
           control major  operating and financial  policies of the local limited
           partnership  and therefore  uses the equity method of accounting  for
           its investment in the local limited  partnership  in accordance  with
           paragraph 10 of SOP 78-9.

Recent Accounting Pronouncements

2.   Comment:  In a  supplemental  response,  please  tell us the basis for your
     determination  the  partnerships  are not VIEs.  Specifically,  address the
     proportional voting rights and entity activities conducted on behalf of any
     investor that may have disproportionately few voting rights as described in
     paragraph 5c of FIN 46. In doing so, please explain your  relationship with
     the  general  partner  of  each  Local  Limited  Partnership  and  how  you
     considered that  relationship in your analysis.  Additionally,  address the
     decision making rights and related equity investment at risk of the holders
     of the equity investment as described in paragraph 5b.

     Response:   The   Partnership's   determination   that  the  local  limited
     partnership is not a VIE was made based on consideration of paragraphs 5, 9
     and 10 of FASB Interpretation No. 46 (revised December 2003), Consolidation
     of Variable  Interest  Entities (FIN 46R). The Partnership first considered
     paragraph  5(b)(1)  of FIN 46R and  determined  that the  group  of  equity
     holders at risk was comprised only of its limited  partners (the group that
     contributed the capital  necessary to fund acquisition  properties owned by
     local limited partnerships). The general partner was not considered to have
     significant  equity at risk either  because its  capital  contribution  was
     insignificant  or because its initial  capital  contribution  was offset by
     fees  received at inception.  The limited  partners were deemed to have the
     right to make  decisions  that have a significant  effect on the success of
     the local limited  partnership  through their ability to remove the general
     partner without cause.

     The Partnership next considered  paragraph  5(b)(2) and determined based on
     review of the local limited partnership  agreement that the group of equity
     holders at risk (the  limited  partners)  do not lack the ability to absorb
     expected  losses,  are not protected  from the expected  losses and are not
     guaranteed a return.

     The Partnership next considered  paragraph  5(b)(3) and determined based on
     review of the local limited partnership  agreement that the group of equity
     holders at risk (the limited  partners)  do receive the  expected  residual
     returns and are not subject to caps on expected returns.

     The  Partnership  next  considered  paragraph 5(c) and determined  based on
     review of the local limited partnership  agreement that the general partner
     is generally the equity holder who is involved in the partnership  activity
     of real estate  development  and operations  and also benefits  through the
     receipt of fees for services provided to the local limited  partnership and
     the right to  receive  distributions  from the local  limited  partnership.
     Therefore the Partnership  does not believe that  substantially  all of the
     activities of the local limited partnership  involves,  and is performed on
     behalf of, the investor (the limited  partner) that has  disproportionately
     few voting rights. Also, as stated above, the limited partner was deemed to
     have the  right to make  decisions  that have a  significant  effect on the
     success of the local limited  partnership through its ability to remove the
     general partner without cause.

     In  conjunction  with the  evaluation of paragraph  5(c),  the  Partnership
     reviewed  the  relationship  of the  general  partner of the local  limited
     partnership with the Partnership.  As previously noted, the general partner
     of the  Partnership,  NHP, also serves as the general  partner of the local
     limited partnership.  The limited partnership  agreement provides that NHP,
     in acting and performing its duties as general partner of the local limited
     partnership,  shall  at  all  times  exercise  its  responsibilities  in  a
     fiduciary  capacity,  and in a manner consistent with the objectives of NHP
     as set forth in Title IX of the Housing and Urban  Development Act of 1968.
     NHP  in  acting  and  performing  its  duties  as  general  partner  of the
     Partnership  must  also  exercise  its  duties  in  a  fiduciary  capacity.
     Therefore,  the Partnership  determined that NHP acts in the best interests
     of  the   respective   entities  it  is  obligated  to  represent  and  the
     relationship  of NHP to the Partnership  does not affect the  Partnership's
     determination   that  the  activities  of  the  respective   local  limited
     partnerships do not involve and are not performed on behalf of the investor
     (the limited partner) that has disproportionately few voting rights.

     Finally,  the Partnership  considered  paragraphs 5(a), 9 and 10 of FIN 46R
     and  determined  through  review of financial  information  and  accounting
     records  for  the  local  limited   partnership   that  the  local  limited
     partnership  lacked  additional  financial  support  from  partners to fund
     operations  (i.e., the local limited  partnership has demonstrated  that it
     can  finance  its  activities  without  additional  subordinated  financial
     support).

     The Partnership believes that based upon the application of paragraphs 5, 9
     and 10 of FIN 46R as discussed above, that the local limited partnership is
     not a variable interest entity.

                        *     *     *     *     *

As  requested  by  the  Staff,  the  Partnership   acknowledges  that:  (a)  the
Partnership  is  responsible  for the adequacy and accuracy of the disclosure in
the filings;  (b) Staff  comments or changes to  disclosure in response to Staff
comments do not foreclose the Commission  from taking any action with respect to
the filings;  and (c) the Partnership may not assert Staff comments as a defense
in any  proceeding  initiated by the  Commission or any person under the federal
securities laws of the United States.

If you have further questions regarding the information provided, please contact
the undersigned or Stephen Waters.  Mr. Waters can be reached  directly at (864)
239-1554 or by fax at (864) 239-5824.

                                   Sincerely,

                                    /s/ David R. Robertson
                                    David R. Robertson
                                    President and Chief Executive Officer
                                    The  National   Housing   Partnership  and
                                    National     Corporation    for    Housing
                                    Partnerships,   the  general   partner  of
                                    National Housing  Partnership  Realty Fund
                                    Two

cc:  Stephen B. Waters

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